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Roger Clarke's 'Privacy Policy Statements'

The Effectiveness of Privacy Policy Statements

Roger Clarke **

Version of 16 December 2008

Chapter 4 in 'Digital Business Security Development: Management Technologies' (Eds. Kerr D., Gammack J. & Bryant K.), IGI Global, 2011, pp. 84-111

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This document is at http://www.rogerclarke.com/EC/PPSE0812.html


Abstract

An expectation exists in the U.S.A. that operators of business-to-consumer (B2C) web-sites will provide public notice of their practices in relation to the personal data that they hold. Such documents are referred to in this paper as 'privacy policy statements' (PPS). Privacy is an important element in consumer trust, and hence in a consumer's decision to make purchases using Internet commerce services. PPS could therefore be expected to play an important role in overcoming the impediments to consumer purchases online.

This paper adds to the growing research literature on PPS by developing a research design involving comparison of an organisation's PPS against a normative template. A pilot study of six B2C sites was undertaken, in order to assess the practicability of the design, and provide some initial substantive insight into the contributions that PPS currently make to consumer trust.


Contents


1. Introduction

It has become common for operators of B2C eCommerce web-sites to explain their practices in relation to the personal data that they gather about consumers. The documents containing the explanations are called by a variety of names, including 'privacy policies', 'privacy statements', 'privacy notices', and 'information practice statements'. This paper uses the term 'Privacy Policy Statement (PPS)'.

PPS emerged in the U.S.A. in the mid-to-late 1990s. The U.S. has no generic private sector privacy legislation, with its national Parliament clinging to the beliefs that business should remain as unfettered as possible, and that self-regulation is an alternative to genuine regulation of business activities. PPS were intended to be an element in that framework. Their use has spread, however. They have come to be used in jurisdictions where data protection laws exist and the statement's impacts and purposes are rather different.

A great deal of the literature on this topic to date has been conducted from the perspective of U.S. law, policy and practices, and most of the empirical studies have been undertaken in the U.S.A. Because U.S. law is so much more permissive than the laws of other economically advanced countries, the U.S. is emphatically not an appropriate context for works that are intended to have meaning for international audiences.

The research on which this paper is based accordingly adopts an approach different from most prior studies. The work began with a normative template that was previously developed on the basis of laws, policies, practices and public expectations around the world, taking into account OECD Guidelines, European Union Directives, and laws in European countries, Canada, Australia, New Zealand and Hong Kong.

A pilot study was undertaken to evaluate a number of PPS against that normative template, in order to assess the extent to which they were likely to represent effective protection for consumers' privacy. This is a further project in a long-running research program undertaken by the author in the area of privacy and information technology generally, in the context of the Internet in particular, and in businessoto-consumer (B2C) eCommerce specifically. As a result, about 15 of the c. 80 citations are to prior refereed papers by the author of this chapter. These provide fuller analyses and arguments supporting many of the points made, together with many further references to the relevant literature.

The paper commences by reviewing the role of privacy as a trust factor in Internet-based B2C eCommerce. This is followed by a consideration of the various means whereby privacy can be protected. The role and nature of privacy policy statements is delineated, existing conventions are identified, and an evaluation template proposed.

A research design is developed to investigate the effectiveness of privacy policy statements from the perspective of consumers. This includes attention to the population of B2C services, population segmentation, and sampling frames. A small sample is selected, and a pilot survey conducted. The results provide a basis for refinement of the research design, and lay the foundation for conduct of more substantial surveys.


2. Privacy as a Trust Factor

According to the Theory of Reasoned Action (TRA) of Ajzen & Fishbein (1980), trust and risk are major determinants of attitude towards purchasing, and hence of intention to purchase. In the context of Internet-based B2C eCommerce, trust is usefully defined as confident reliance by one party about the behaviour of other parties (Clarke 2002a).

The concept of trust originates in familial and social settings, where parties have considerable mutual understanding, mutual interests, and mutual dependence. The strongest sources of trust arise from a pre-existing direct relationship between the parties, primarily kinship and mateship, but also to some extent from such commercial forms as principal-agent relationships, contract and multiple prior transactions (Clarke 2002a). A less strong source is direct experience, as arises from a prior transaction, or perhaps prior exposure to the organisation concerned, e.g. by watching a trusted friend conduct a transaction. Weaker again is referred trust, such as 'word-of-mouth' and reputation. Still weaker are mere symbols of trust, which are often nothing more than contrived images, in the form of brands. The weakest form of all is 'meta-brands', such as accreditation and 'seals of approval', especially from industry associations that lack the power and/or the will to regulate even their members let alone non-members (Clarke 2001b). The strongest forms of trust are difficult to replicate in merely economic relationships. In B2C eCommerce, trust is in practice simply what the consumer is forced to depend on when no other form of risk amelioration strategy is available.

Trust is not easy to achieve in Internet contexts. The parties have little knowledge about one another, and cannot depend on such confidence-engendering measures as physical proximity, handshakes, body language, a common legal jurisdiction, or even necessarily any definable jurisdiction (e.g. Lee & Turban 2001, Clarke 2001c).

When business interests finally discovered the Internet in the mid-1990s, it was assumed that electronic commerce would explode. In fact, adoption was far slower than most Internet growth metrics, because business failed to address the trust gap. This was examined in Clarke (1999b).

Trust issues are many and varied. Some are related to the terms and conditions under which consumers buy from business enterprises, especially their non-negotiability, their imbalance in favour of the vendor, the location of the contract in a jurisdiction that suits the vendor rather than the customer, and the lack of consumer protections that the consumer normally enjoys when purchasing goods and services in their home jurisdiction. Further concerns arise in relation to default by the vendor or by the carrier selected by the vendor. Yet more are security issues, relating to the consumer's identity and personal data, including the person's location, contact-points and credit-card details.

This paper is concerned with the particular cluster of impediments to the adoption of B2C eCommerce that are associated with privacy. Privacy is the interest that individuals have in sustaining a 'personal space', free from interference by other people and organisations (Clarke 2006a). There are many dimensions of privacy. The one most relevant to the present context is personal data privacy. Key requirements include the individual's ability to prevent data about themselves being available to other individuals and organisations, and, where data is available, the ability to control its quality, use and further disclosure.

The role that privacy plays in the achievement of trust has been examined by various researchers (e.g. Palmer et al. 2000, Clarke 2001c, Belanger et al. 2002, Xu et al. 2003). The fundamental requirements are that the amount of personal data available to the marketer must be minimised, and such data as is available must be, and be perceived by consumers to be, protected against abuse by the marketer and others. This may be achieved through substantive measures combined with effective communication of their existence to consumers; or by effective communication based on as limited an actual set of constraints as the organisation can get away with. There are significance cultural differences in the importance placed on privacy, and its role in trust (e.g. Dinev et al. 2005, Kim 2005).


3. Privacy Protection Mechanisms

Several different approaches are taken to privacy protection. This section briefly reviews ways in which online marketers can design their business processes to be privacy-sensitive, and can use technology as an antidote as well as a threat. It culminates in a summary of the ways in which the law can be used to protect privacy. Together, these define key aspects of the various contexts within which PPS can be applied.

3.1 Business Process Protections

Until the early-to-mid twentieth century, most consumer transactions were conducted in physical marketplaces. Judgements were made based on the information available at the time the decision was made, and little data was stored. Progressively, as managerial rationalism took hold, as labour became more efficient through specialisation, and as consumer marketing businesses became larger, more personal data came to be captured. During the second half of the twentieth century, enormous advances in information technology resulted in the capacity for marketers to depend more and more on data as a substitute for knowledge of their customers, and to become more and more remote from them.

But businesses can choose the appropriate degree of dependence on intensive personal data. They can enable anonymous and pseudonymous purchasing, by denying themselves the opportunity to consolidate data about each customer, to use it, and to pass it on to others. Even where they transact with known identities, they can limit the data that they retain (as some vendors do, for example, by not retaining credit-card details, or not retaining some part of it, such as the last four digits). Businesses that hold identified data need to implement appropriate organisational security measures to protect it.

It was suggested in Clarke (1998) that direct marketing using electronic channels would be more successful if the following principles were applied:

3.2 Technological Protections

Information technology has been primarily harmful to the privacy interest, resulting in increasingly widespread use of the term Privacy-Invasive Technologies, or 'the PITs' (Clarke 2001a). A movement has been in train for a decade now, intended to apply information technology in support of privacy rather than against it. This goes under the name Privacy-Enhancing Technologies (PETs), a term which appears to have originated in IPCR (1995). See also EPIC (1996-) and Burkert (1997). Specialist PET Workshops have been held annually since 2001.

(Clarke 2001a) distinguishes three broad kinds of PETs:

3.3 Legal Protections

Several heads of law may provide privacy protections. In common law jurisdictions, the torts of breach of confidence and passing off may have some limited applicability. In addition, a tort of invasion of privacy has been very slowly emerging, because of the failure of Parliaments to enact appropriate legislation. The legal measures of greatest relevance are explicit privacy laws, explicit data protection statutes, incidental privacy provisions within other statutes, contract, and laws relating to misleading statements.

Comprehensive privacy statutes, providing protections for all of the multiple dimensions of privacy (Clarke 2006a), are almost unheard of, although the human rights provisions in many countries' constitutions at least provide some basis for the development of case law.

The first data protection statute, on the other hand, was passed in 1970 in the German Land of Hesse. Since then, most 'advanced western' nations have enacted such laws. These all reflect the 'fair information practices' (FIPs) movement, which originated in U.S. business and government circles in the late 1960s, and flowered in Europe during the 1970s (Flaherty 1989, Bennett 1992). FIPs was codified in the OECD Guidelines (1980).

The FIPs notion was intended to protect the interests of business and government, so it is no surprise that legislaiton based on it provides seriously inadequate privacy protection. FIPs-originated laws are of narrow scope, embody manifold exemptions and exceptions, and omit key control mechanisms (Clarke 2000). Moreover, laws in most jurisdictions reflect the technology of the 1970s rather than that of the new century. FIPs has become so engrained, however, and the dominance of economic over social needs so strong, that privacy advocates have been at best only partly successful in their endeavours to shift the focus of public policy away from the nominal protection of data, back to the protection of people's privacy.

Almost alone among leading nations, the U.S. Congress has failed to enact comprehensive consumer privacy legislation. Many incoherent and narrowly sector-specific laws exist, however, arising from flurries of public concern arising in such areas as health records, video rental records and the privacy of children. Provisions of this nature are largely redundant in most countries with comprehensive data protection laws, and they are not a primary focus of this paper.

In response to the demands of business lobbyists, he U.S. Federal Trade Commission (FTC) sought during the 1990s to roll back even the limited protections that had emerged from the FIPs movement. It issued its own, even more inadequate set of a mere four 'widely accepted fair information principles' - 'notice', 'choice', 'access' and 'security', to which it later added a fifth - 'accountability' (FTC 2000).

This brought the U.S. into conflict with the E.U., because many U.S. consumer marketing corporations are active there. After a period of uncertainty, the E.U. chose to ignore the concerns of its advisory group (Art.29 2000), and backed down on key requirements. It permitted the U.S. to devise a so-called 'Safe Harbor' program (DOC 2000). This is an extension to the FTC's cut-down version of FIPs - with the original five principles supplemented by 'onward transfer', 'data integrity' and 'enforcement'; but despite the name of the final principle, the scheme is not subject to effective enforcement.

More recently, the U.S. Administration, through the Department of Commerce, has sought to undermine the OECD Guidelines by exerting its influence on members of the Asia-Pacific Economic Cooperation (APEC), in order to achieve publication of an alternative, much weaker set of principles (APEC 2004).

Contract law may also provide a basis for privacy protections. Vendors may offer explicit terms that the courts will treat as part of the contract, binding vendor and consumer alike. Assurances about privacy protection may be embedded into those terms. Even where they are not, it is open to the courts, at least in common law jurisdictions, to find conditions to be implied in contracts. A PPS can form part of the terms of contract that the vendor and consumer enter into, either by the vendor's terms expressly reading in the PPS, or by the courts regarding the PPS as being an implied term of the contract. The effectiveness of contract as a privacy protection is very limited, however. There is often vast disparity between the resources and market power of the parties, and the jurisdiction in which an action must be brought is often distant from the consumer, and is usually incomprehensible to them, and too expensive for them to utilise.

A further head of law of potential significance is provisions that make misrepresentation an illegal act. In common law countries, tort law may render misrepresentation a breach of the offended party's civil rights. Many countries have created statutory obligations of a similar nature, and some recognise criminal misrepresentation. Examples include the U.K. Misrepresentation Act 1967, the Australian Trade Practices Act 1974 s.52, and Fair Trade Practices and Misrepresentation statutes in the various Australian States and Territories. If the PPS takes the form of an undertaking by the vendor (rather than just a vague description or inherently untrustworthy advertisement), then it may be feasible for it to serve as the basis for an action under such laws. In many cases, however, such actions may be brought only by a particular regulator, which fails to do so. As a result, the provision is nugatory, i.e., like most potentially privacy-protective laws, literally worthless.

The U.S. is a particularly important example in this case, because of the absence of comprehensive privacy legislation. The Fair Trade Commission Act s.5(a) renders illegal an unfair or deceptive act or practice. This has been claimed to provide as a sufficient restraint on privacy-abusive practices by American business (e.g. FTC 2005?). But the FTC has serially failed its obligation to enforce those provisions, having pursued only 15 cases in 7 years, in the world's largest and most dynamic economy. The claims are hollow. The FTC is consistent in its defence of business enterprises against privacy laws. It gutted the child protection law, by determining that Amazon.com's Toy Store web site is "not directed at children" (EPIC 2004). Any organisation can now unilaterally declare itself outside the scope of the Act simply by including a statement that it "does not sell products for purchase by children" - despite the fact that children are highly unlikely to take any notice of such statements.

The U.S. self-regulatory 'safe harbor' scheme has proven completely inadequate (Hoofnagle 2005, Connolly 2008), and is a much poorer deal for consumers than the inadequate FIPs-inspired laws in other countries. The longstanding calls for FIPs legislation in the U.S.A. (e.g. Clarke 1999a), which were temporarily quietened in the years immediately following the terrorist strikes of September 2001, have resumed, with American business reported to be in support of regulation (e.g. Economist 2005).


4. Privacy Policy Statements

In the mid-to-late 1990s, it became fashionable in the U.S. for corporations to publish statements on their web-sites about their privacy practices (FTC 1998a, 1998b, Hoffman et al. 1999). The notion has been adopted in other countries as well. In many countries it is primarily symbolic, because a data protection statute that regulates the private sector is far more likely to be effective than a mere statement by the organisation itself.

This paper adopts the view that, although a mere statement can only be a small part of a comprehensive approach to privacy protection and hence consumer trust in B2C eCommerce, there is nonetheless potential value in PPS. The reasons are as follows:

A variety of researchers have examined various aspects of web-site privacy statements. Foundation works included Culnan (1993) and Smith et al. (1996). Important among the analyses and empirical investigations have been Wang et al. (1998), Anton & Earp (2001), Earp et al. (2002), Lichtenstein et al. (2002), Milne & Culnan (2002), Earp & Baumer (2003), Lichtenstein et al. (2003), Culnan & Bies (2003), Jensen & Potts (2004), Gauzente (2004), Kobsa & Teltzrow (2005), Milne et al. (2006) and Anton et al. (2007).

Some articles have focussed on the benefits to business enterprises of a PPS. Meinert et al. (2006) reported on a survey that showed that "the willingness [of graduate students] to provide information to Web merchants increased as the level of privacy guaranteed by the [privacy] statements increased". Hui et al. (2007) used a field experiment to show that "the existence of a privacy statement induced more subjects to disclose their personal information but that of a privacy seal did not". Schwaig et al. (2004, 2006) and Hooper et al. (2007) noted the effectiveness of PPS for big businesses, despite the very limited protections they afford.

Other articles are more doubtful, variously about the quality and the value of PPS. Regan (2001) noted how infrequently they were accessed. Many authors have drawn to attention their complexity, notably FTC (2000) and Culnan & Milne 2001. Dubbeld (2006) concluded that "the underdeveloped state of online privacy notifications [on telecardiology Web sites] is disappointing". Markel (2008) found that "of 20 randomly selected US companies that claim to be in compliance [with the low-grade and unenforced U.S. 'safe harbor' norms] ..., 19 are not ...".

Kobsa & Teltzrow (2005) concluded that "76% of users find privacy policies very important, and 55% stated that a privacy policy makes them more comfortable disclosing personal information. However, privacy statements today are usually written in a form that gives the impression that they are not really supposed to be read. And this is indeed not the case: whereas 73% of the respondents ... indicate having viewed web privacy statements in the past (and 26% of them claim to always read them), web site operators report that users hardly pay any attention to them". This conflict between the apparent importance of privacy and the limited use of privacy statements has been referred to as a "disconnect between public opinion and public behaviour" (Regan 2003).

This 'disconnect' reflects the highly situational nature of privacy. Most of the time, most consumers are only vaguely concerned about privacy, and lack the motivation to seek out and read carefully phrased, turgid 'legalese'. But even vague concerns represent an impediment to the adoption of eCommerce. Moreover, once an individual consumer's concerns are triggered, the person may easily become an active avoider of web-commerce. In response to the limited use of PPS by consumers, the concept of 'layered notices' has been developed "to provide an easy to read one-page summary of a company's online privacy practices while conforming to all regulatory requirements and giving links to full legal statements and other relevant information" (Fleischer 2005. See also Crompton 2004). It is unclear whether the initiative has delivered any value to consumers.

Only limited guidance is available in the literature as to what constitutes an appropriate form for a PPS. One important exception is the linked documents OECD (2000a and 2000b). The Committee of European Data Protection Commissioners, meeting as the EU's Article 29 Working Group on Data Protection, has been reported as having published guidelines on corporate privacy notices in late 2004 (e.g. Pruitt 2005). But a search on the Article 29 Committee's web-site failed to provide access to a copy. A preliminary document is visible on the site of the German Federal Data Protection Commissioner (ICDCP 2003).

The web-sites of the various privacy protection agencies provide almost no assistance, although a publication of the U.K. Commissioner is of some relevance (ICO 2001). There are no guidelines apparent on the sites of the U.S. FTC, or even of the leading U.S. advocacy group EPIC and the more business-aligned groups CDT and EFF. Some guidance is provide by TRUSTe (2004 and 2005), BBB (2003) and Freenetlaw.com (2008); but those documents are seriously limited, because they merely advise compliance with the FTC's minimalist FIPs model and a few U.S. sector-specific laws. Guidance intended for government agencies may also be of assistance, such as OFPC (2000?), AGIMO (2003) and TSB (2004).

As a prelude to the project reported on in this paper, this author drew on prior research, including the above sources, in order to compile a Privacy Statement Template. This is at Clarke (2005a), with accompanying comments in Clarke (2005b). The Template is normative, by which is meant that it is a compilation of the needs of consumers, and is not compromised by the exercise of market power by business enterprises, nor by the limited provisions of FIPs-based data protection laws. The Template stipulates requirements in the areas of data collection, data security, data use, data disclosure, data retention and destruction, access by data subjects to personal data, information about data handling practices, the handling of enquiries, general concerns and complaints, enforcement, and changes to privacy undertakings. The Template was applied in the research that is described below, as a basis for evaluating the PPS published by B2C vendors.


5. Research Design

The general research question being pursued in this study is: 'How effective are Privacy Policy Statements in encouraging consumer trust of B2C vendors?'. The model that is assumed is as depicted in Exhibit 1. Consumer trust is heavily dependent on the vendor's perceived privacy sensitivity. That perception is in turn heavily dependent on the characteristics of the vendor's privacy policy statement.

Exhibit 1: Research Model

The purpose of the research is to consider the effectiveness of PPS from the perspective of the consumer. The research focusses on contexts in which vendors are seeking to implement substantive rather than merely image-based privacy protections. It also leaves to one side the need for effective marketing communications, to ensure that consumers understand that the protections are in place.

The operational interpretation of the research question is: 'Do the Privacy Policy Statements found on vendors' web-sites measure up to the requirements expressed in the normative Privacy Statement Template'?

The vendor population is defined as those B2C services that are accessible on the World Wide Web. For simplicity, it does not encompass other forms of B2C eCommerce, such as emergent mobile services accessed through means other than web-browsers. This is nonetheless a highly diverse set of services. It is therefore important to analyse the population into meaningful segments, and probably important to over-sample from some of those segments. Exhibit 2 suggests a two-dimensional segmentation model that would appear to be appropriate to the research question.

Exhibit 2: Population Segmentation

Company-Type
Description
Justification
   
Dimension 1 – The Company Patterns in these two sub-categories may be materially different, because consumer trust is easier to achieve in an organisation with physical presence

A: 'Pure Internet' B2CCorporations that do not have a separate physical operation 
B: 'Clicks and Mortar' B2CCorporations that do have a separate physical operation 
   
Dimension 2– The Business Patterns in these five sub-categories may be materially different, due to various characteristics of the business and its context
A: LeadersBusinesses acknowledged as trend-setters in this fieldIt would be valuable to over-sample this category, because it offers an indication of future directions
B: Aggressive MarketersBusinesses recognised as being strong and direct in their approach to consumers These businesses could be expected to be either disdainful of privacy, or manipulative and image-conscious
C: Marketers of Sensitive ProductsBusinesses that sell goods and services whose purchasers are likely to be particularly concerned about privacyThese businesses could be expected to be highly subject to, and very well aware of, the need for effective privacy and visible privacy protections
D: Regional MarketersBusinesses primarily active in particular jurisdictionsCompanies that are subject to data protection laws could be expected to adopt different approaches to those that are not subject to such laws
E: 'Ethical' / Not For Profit MarketersBusinesses run by organisations that espouse strong values in relation to privacyThese operations could be expected to have adopted positive approaches to privacy protection

For each segment, a sampling frame is needed. Examples include, for Market Leaders, businesses that receive frequent mentions in the media in relation to their privacy statements and consumer terms. For Aggressive Marketers, those organisations could be considered that have won awards for their B2C operations from such organisations as the (U.S.) Direct Marketing Association (DMA), or for whom Harvard case studies have been prepared. For Marketers of Sensitive Products, directories of on-line sex-shops and on-line gambling services could be consulted. Regional directories would provide links to marketers subject to the laws of particular jurisdictions. For 'Ethical' Marketers, directories of not-for-profit B2C operations, including charities, could be consulted.

Audit of the organisation's compliance with its PPS, and contact with the organisation to seek any clarifications are highly desirable. Such procedures are highly resource-intensive, however, and long delays and refusals might be anticipated. It is therefore envisaged that all judgements will be based on the PPS review, supplemented by experiments with the relevant service.


6. The Pilot Survey

A pilot survey was conducted. The primary purpose was to gain insight into the efficacy and practicability of the design, preparatory to its wider application. A secondary purpose was to gather information of relevance to policy discussions. The first assessments were performed in January 2006, with a follow-up in December 2008 to check the extent to which the content and presentation were stable or were in a state of flux.

6.1 The Sample

A small set of organisations was selected, in order to test the application of the Template to the PPS published by a manageably small list of organisations. These were selected in order to ensure some diversity, and to provide the prospect of results with some policy value.

The organisations selected for evaluation are listed in Exhibit 3. The two market-leaders are very apparent from media and popular discussions. The choice of a German company was based partly on the fact that the country has the longest history of data protection laws, and partly on the pragmatic grounds that German is the only language other than English that the author can read, and that he has more familiarity with data protection laws in German-speaking countries than with those in other parts of Europe.

Exhibit 3: Pilot B2C Businesses

6.2 Results

This section provides a brief summary of the outcomes. The detailed assessment sheets are available on the Web, and the archived copies of the PPS that were evaluated are available from the author on request.

National Geographic and Google both implement the 'layered notice' notion by offering a 'highlights' page as well as a PPS. Google provides further PPS in respect of some of its services. The other organisations in the sample offer a single web-page, ranging from an equivalent 1-1/2 pages of A4 (Adultshop.com) to 4-6 pages (Amazon, Autoteile-Meile.de and National Geographic).

Amazon declared for itself extraordinary latitude in its handling of personal data. The effect of the statements was essentially that it collects personal data from wherever it wants to, uses it however it wants to, and discloses it to whomever it wants to. It provided minimal information on data security, none on data retention and destruction, little on amendment, and none on deletion of personal data.

In common with many other organisations, it provided no access to previous version of its PPS. Amazon had previously changed its PPS, reneging on previous undertakings, and providing itself with additional latitude (e.g. Rosencrance 2000a, 2000b). It has also been accused of breaches of the Children's Online Privacy Protection Act (EPIC 2003), although the FTC found a way to ensure that the breach was only of the spirit rather than of the letter of the law (EPIC 2004).

On re-visit, the date of latest change was visible, as was an explanation of what the changes had been. This represented a procedural improvement, but the mechanism remained deficient in that no chain was provided back to earlier versions. The changes in the PPS provided no substantive improvement, however. Amazon remains privacy-hostile.

The analysis of the Google PPS was the subject of Clarke (2005c and 2006b). Serious shortfalls were identified in many areas. These included the particular use of cookies, the vagueness of the statements about the purposes of the data Google collects, its transfer of personal data across borders, the absence of assurances about relevance and quality of personal data, its apparent attempt to obfuscate the meaning of 'consent', its failure to take any responsibility for personal data transferred to affiliates or to any other organisation, its failure to even address data retention and destruction issues, its failure to provide information about its data-handling processes, even on request, the general unenforceability of the assurances given, and the complete absence of protections in the event of merger, acquisition, or even sale of assets. In short, the several positive aspects of Google's PPS were completely swamped by very serious deficiencies.

On re-visit, a single further version had been added to the chain, and all remained visible. However, no indication was provided of what change(s) had been made, and the wide range of serious shortfalls remained. Some other changes of relevance had occurred, however. In mid-2008, Google at last adopted the widespread norm of having a link to the PPS from the home-page. Further, it responded to a few of the many criticisms levelled at it by privacy advocacy organisations, by providing 'layered statements' (i.e. a short version as well as the long one), by providing links to the more specific PPS for particular services, and by providing access to various videos it has published that are of relevance to privacy questions. However, no index exists of the video content, and it is far from clear that such statements as are made in them are binding on the company. Google is a huge threat to the privacy not only of its users, but also of people who correspond with gmail users.

Testing of the Sears site was made more difficult by its non-standard or bug-laden code, which caused malfunctions of the mainstream Mac Mozilla 1.7.8 browser being used. The PPS was found to have a wide array of deficiencies, not unlike Google's, but in some respects worse. For example, the concept of 'voluntary provision' of personal data was used in relation to data whose provision appears to be a condition of dealing; collection from and disclosure to third parties is undertaken on a non-consensual basis; the company appears to have no concept of data destruction on expiry of use; and no information is evident about any complaints process. This is consistent with a consumer-arrogant operation rather than a privacy-sensitive stance.

On re-testing, the incompatibilities with mainstream browsers appeared to have been overcome. A date of last change was provided, but no indication was given of the changes made, and no chain was offered back to prior versions. There was considerable cosmetic change, but little in the way of substantive improvements appeared to have been made. Moreover, a catch-all disclaimer had been added: "While we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information will always remain private". In short, Sears' policies continue to be seriously privacy-hostile.

Adultshop.com is admittedly a very much smaller operation than the previous three, but its PPS is the antithesis of theirs. The PPS is expressly used as part of its positioning: "Our business success depends on our discretion and our understanding of the importance of your privacy. If you have suggestions for enhancing our privacy policy, please contact me directly ... Malcolm Day, Managing Director". All statements are directly expressed, and all options taken are privacy-sensitive. It falls short of the Template's requirements on many details (e.g. re data retention, access by the data subject, changes to the PPS, and acquisition, merger and sale of business). But many of these weaknesses are far less important because of the business process design.

It is possible that the site's privacy-sensitivity reflects the fact that the organisation is subject to a data protection law (the Australian Privacy Act's private sector provisions, enacted in 2000). That is, however, a very weak implementation of the (in any case, inadequate) OECD FIPs model, and it is reasonable to infer that the needs of the company's customers were a significant factor in determining its approach. No changes were apparent on re-visit in late 2008.

The German company, Autoteile-Meile, is subject to the German data protection law, the Bundesdatenschutzgesetz ss. 1-11 and 27-46. Remarkably, however, its PPS is largely a German translation of the current Amazon PPS (to the extent that it appears that it may be in breach of Amazon's copyright). It therefore inherits a large proportion of the weaknesses of that document.

A number of modifications are apparent, to reflect the provisions of the German law. Others that might have been expected have not been made, however. Amazon has successfully opted out of the U.S. child privacy regulatory scheme merely by putting some well-chosen words on its web-site; but such corporation-friendly looseness is not a feature of European laws.

It appeared that Autoteile-Meile's PPS might have been merely experimental, because it would seem to have little or no status under German law. On re-visit, however, the PPS was still there, and the version was of a later date. Apart from some editing, the primary changes appeared to be the inclusion of a reference to a specific EU document, and a new section on Choice.

The PPS published by National Geographic was remarkable in two ways:

The privacy terms were arguably far worse even than those of Sears, Roebuck and Co. They failed dismally in relation to all of data collection, security, use, disclosure, retention and destruction, personal access and complaints-handling. They imposed opt-out where consent (opt-in) is the norm. They provided no means to communicate complaints to the company. Although it appears that the PPS may have been designed by a very clever lawyer so that it gave the appearance of compliance with the letter of the FTC's suggestions, it is non-compliant, at the very least with the basic choice and access principles, and the additional onward transfer and enforcement principles. Perhaps large U.S. not-for-profit organisations have become imbued with the aggressive ethos of American corporations. National Geographic was included in the pilot as a member of the 'ethical' segment, but its ethicality seemed to be limited to honesty about the organisation's privacy-hostile stance.

On re-visit, some uncertainty arose from date-inconsistencies in the old and new pages. But the PPS did not appear to be substantively different from that previously reviewed.

Observations arising from the pilot evaluations are as follows:

One outcome of surprise was that it was not always as easy as it should be to discover the PPS. This identified the need to add an Accessibility requirement into the Template. In most cases, the PPS was accessible from the home-page and from pages typically used during a consumer transaction. But Google did not have a link on its main pages at www.google.com, nor in country-specific services such as www.google.com.au nor even www.google.de, until mid-2008. It was necessary to follow the link to 'About Google' to find the link. All of the others offered the link in the page-footer, and some also draw it to attention at a relevant point in the purchasing process.

Other omissions from the template that became apparent during the course of the evaluations were:

Some doubt was thrown on the segmentation used in the research design. In particular:


7. Conclusions

In order to overcome consumer concerns about privacy-invasive practices in B2C eCommerce, there is no substitute for legal protection. Privacy policy statements originated within the U.S. 'self-regulatory' context. They are, however, capable of playing a role within a statutory data protection framework as well.

A research design was prepared, to enable evaluation of privacy policy statements against a normative template. A pilot survey applying the design to six organisations has established that the design required refinement, but was largely appropriate.

To the extent that substantive conclusions can reasonably be drawn from the pilot survey, it appears that major American corporations, and even not-for-profits, fall far short of the privacy-sensitive norms that consumers would reasonably expect in relation to the handling of personal data. More consumer-friendly practices appear to be associated with two factors: a statutory framework for data protection, and vendors of especially sensitive goods and services. These tentative inferences of course need to be tested through the evaluation of a larger, and more representative sample of privacy policy statements, and extension beyond B2C eCommerce to Mobile Commerce.

Complementary research is needed, to address aspects of the research question that were intentionally left to one side. In particular, studies are needed of the extent to which consumers understand the degree of privacy-protectiveness that they do and do not enjoy when using different companies' services, and the extent to which their adoption and non-adoption decisions reflect that understanding.


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Acknowledgements

An earlier version of this paper was presented at the 19th Bled eCommerce Conf., Slovenia, 5-7 June 2006. This version reflects the comments of informal commentators, referees and conference delegates.


Author Affiliations

Roger Clarke is Principal of Xamax Consultancy Pty Ltd, Canberra. He is also a Visiting Professor in the Cyberspace Law & Policy Centre at the University of N.S.W., a Visiting Professor in the E-Commerce Programme at the University of Hong Kong, and a Visiting Professor in the Department of Computer Science at the Australian National University.



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